Corrective Action Plans

Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurately. Corrective Action Plan: The institution has taken and has fixed this issue by: • The system is now functioning correctly after addressing the issue with the vendor. • To prevent future issues, a more robust tool has been developed to identify discrepancies promptly should they arise. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/2025

Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. During our testing of compliance for HEA Credit balances, there were 5 instances out of 60 where the College did not refund a student’s within the required time frame of 14 days from the first day of class or 14 days after the credit balance was created. Corrective Action Plan: The institution has taken and has fixed this issue by: • Dedicated Staffing: A full-time position has been approved and filled to manage stipend processing, ensuring consistent oversight and timely disbursement. • Process Documentation: Stipend processing procedures have been documented to ensure continuity, accountability, and clarity of responsibilities. • System Review and Planning: The system is up and running as it should have been. • Ongoing Monitoring: Leadership will continue to monitor stipend processing timelines and staffing capacity to ensure compliance and timely student support. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Bethany Parmer – Assistant Dean of Enrollment Services Anticipated Completion Date: 12/31/2025

Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.

Betsy Rohde, CEO/Business Manager for the Colome School District, is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the district's business office. The size of the school district and the monetary resources available prevent the hiring of additional staffing to the business office at the proper levels for internal controls. Planned Corrective Action Plan: The Colome School District has an internal controls policy to identify areas of risk and implements that policy to reduce the risk of any mistakes and inappropriate or illegal activity within the school district. The school board takes an active role in monitoring financials, including reviewing the bank statements, claims, and financial sofware reports each month. They may request any supporting documentation that is not already provided at school board meetings by meeting one on one with the CEO/Business Manager. The principal was added to email alerts of all bank transfers including payroll and ACH payments. This ensures an additional staff member is notified when the CEO/Business Manager makes financial transactions within the school district's bank accounts. The school board will review the policy to identify any areas that still leave a significant risk to ensure all financial activities are monitored by more than one individual. This is an ongoing process.

Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are lost, or documents are damaged due to flooding (which is what occurred in the basement where documents were housed). Cases that are more than 10 years old are typically going to be more difficult to locate needed items, due to records being maintained differently at that time and requirements were different in what the Department was required to maintain in an Adoption file. Proposed Completion Date: June 30, 2026 checking monthly to ensure paper files are scanned into Traverse.

Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was revealed. USDA paid the difference owed on October 28, 2025. Planned Corrective Action: Once the School Nutrition Director completes the monthly claim, Leanne Green, Finance Director, reviews the paperwork, verifying that all is correct before the claim is filed.

Condition: The County did not perform required on-site inspections of four out of six HOME-assisted properties evaluated during FY 2025, as mandated by 24 CFR §§ 92.209(i), 92.251(f), and 92.504(d). These inspections are required every one to three years, depending on the number of units per project. Recommendation: Establish and maintain a formal inspection schedule with assigned accountability to ensure timely completion of all required HOME inspections. Implement tracking tools and cross-training to mitigate delays caused by staff turnover. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Planned in Response to Finding The County agrees with the finding and is implementing the following corrective actions to strengthen internal controls over HOME inspection compliance and ensure inspections are conducted in accordance with federal requirements. 1. Cross-Training of Inspection Staff Housing & Grants staff will conduct formal cross-training with inspectors from Environmental Health and/or the Marin Housing Authority by June 30, 2026. This training will cover HOME inspection requirements, including property standards, documentation expectations, and inspection frequency requirements. Cross-training will ensure sufficient technical expertise and backup coverage to perform and review HOME inspections in compliance with federal regulations and to maintain continuity during staffing changes.2. Implementation of Inspection Tracking Software The Community Development Agency will implement and utilize inspection tracking software by June 30, 2026 to track, schedule, and document HOME program inspections. The system will maintain inspection dates, inspection type (desk audit or physical), findings, corrective actions, and follow-up status. This tool will strengthen monitoring controls, provide management visibility, and help ensure inspections are conducted timely and consistently. 3. Conducting HOME Inspections in Accordance with HOME Regulations Housing & Grants staff will conduct HOME inspections in accordance with HOME program regulations by June 30, 2026, including both desk audits and physical inspections, as follows: • Desk Audits: Staff will review program documentation, tenant eligibility, income certifications, rent limits, and other compliance documentation using standardized desk audit procedures. • Physical Inspections: Physical property inspections will be performed in accordance with HOME property standards to assess health and safety compliance. • Monitoring and Documentation through JotForm Desk Audits: Desk audits will be documented using JotForm inspection and monitoring tools to ensure consistent documentation, clear audit trails, and management oversight of HOME compliance activities. 4. Formal Inspection Schedule and Ongoing Oversight The Community Development Agency has initiated development of a comprehensive HOME on-site inspection schedule that identifies all HOME-assisted properties, applicable inspection frequencies, and assigned staff responsibilities. The schedule will be maintained and reviewed at least quarterly by program management to ensure inspections are completed timely and any overdue inspections are promptly addressed. Responsible Officials • Leelee Thomas, Deputy Director, Community Development Agency Leelee.Thomas@marincounty.gov • Chris Miranda, Senior Program Coordinator, Community Development Agency Chris.Miranda@marincounty.gov Planned Completion Date All corrective actions described above are expected to be fully implemented by June 30, 2026.

Corrective Action Plan: Upon assuming the role of Executive Director in July 2024, it became clear that rent reasonableness studies were not being conducted under the previous administration, as required. Recognizing the importance of compliance with HUD regulations, I initiated the implementation of a rent reasonableness policy and process. To support this effort, we entered into a contract with MRI to provide us with the rent reasonableness software. Last year we supplied MRI with the necessary property addresses and zip codes to begin the analysis. Due to the complexity of the implementation and the volume of data required, the setup process took time. We are now actively incorporating rent reasonableness determinations into all tenant files during annual recertifications and interims. With nearly 700 families in our program, this is an ongoing process, but significant progress has been made. Our team is fully committed to ensuring full compliance with HUD regulations, and we continue to work diligently toward that goal. In addition, to ensure continued compliance and to maintain the integrity of our files, the HCV Supervisor will be conducting weekly audits. This internal quality control measure helps us identify and address any inconsistencies or issues in a timely manner.

Supportive Housing for the Elderly (Section 202) Mortgage Financing– FAL No. 14.157 Section 202 Project Rental Assistance Contract – FAL No. 14.157 Recommendation: When a lack of segregation of duties exists, management’s and the board’s close supervision and review of accounting information are the best means of preventing or detecting errors and irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will continue to monitor monthly financial results and accounting information as correction is not practical. Name(s) of the contact person(s) responsible for corrective action: Jennifer Medearis Planned completion date for corrective action plan: In process

November 21, 2025 CORRECTIVE ACTION PLAN (Concerning Finding 2025-001) Contact person responsible for corrective action: Jennifer Lawcewicz, Superintendent Corrective Action: The Essex North Supervisory Union will take the following actions to address finding 2025-001- Activities Allowed and Allowable Costs: 1. Essex North Supervisory Union has created a purchasing and procurement procedure manual with detailed procedures. 2. The business manager and superintendent have shared this document with all employees that are involved in purchasing. 3. The business manager and the superintendent will have regular meetings with the principal and grants manager to ensure that all procedures are being followed. 4. All invoices will continue to be reviewed by the business manager or the superintendent. 5. Purchase Orders will be issued prior to invoice when applicable. Anticipate completion date: Currently in place and happening

Action Taken enCircle noted during the audit that federal expenditures were being billed into multiple revenue accounts depending on the nature of the expenditure (internal expense, client reimbursable expense, foster parent payments). These accounts have all been consolidated into one account to ensure internal and external reporting does not exclude billed expenditures.

Item: 2025-001 Assistance Listing Number: 64.024 Program: VA Homeless Providers Grant and Per Diem Program Federal Agency: U.S. Department of Veterans Affairs Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: CCAZ999-4582-649-TP-24 Award Year: October 2021 to September 2023; October 2023 to September 2026 Compliance Requirement: Reporting Criteria: In accordance with the grant agreements, the Organization is required to submit per diem financial reports requesting payment based on the units of service provided multiplied by a per diem rate as specified in the grant agreement. Condition: In preparation of the per diem financial reports, the incorrect per diem rate was used to calculate the amount requested for payment for three reports. Phone Number: (602) 650-4852 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Actions: The Organization has implement additional controls to ensure updates to the per diem rates are identified timely. The Organization will continue to ensure reports are reviewed and approved prior to submission to the granting agency. This review and approval will be clearly documented.

Item: 2025-002 Assistance Listing Number: 93.558 Program: Temporary Assistance for Needy Families Federal Agency: U.S. Department of Health and Human Services Pass-Through Agencies: Arizona Department of Economic Security Contract/Pass-Through Grantor Identifying Number: CTR062282 Award Year: July 2024 to June 2025 Compliance Requirement: Reporting Criteria: In accordance with the grant agreements, the Organization is required to submit monthly performance reports. Condition: Of the 22 reports tested, 11 were not submitted timely. Phone Number: (602) 650-4852 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Actions: The Organization has implemented additional controls to ensure reports are submitted timely. The Organization will continue to ensure reports are reviewed and approved prior to submission to the granting agency.

RHC of NEPA has taken significant steps to improve and rectify their sliding fee deficiency over its last 3 audits. RHC of NEPA has improved from 2 consecutive material weakness findings to having substantial improvement and reduced its status to a significant deficiency. It is important to note that 2 of the outstanding claims identified had timely sliding fee documents completed, however they were out of compliance due to human error of calculation of the sliding fee percentage. Education and internal audits which were implemented throughout the organization which have driven the marked improvement will continue to be disseminated throughout the organization. Clearly based on the improvement that has occurred, current processes and level of attention are the correct items to rectify and become fully compliant with sliding fee requirements. These policies will be the focus of additional training with a separate session being dedicated to the updated sliding fee implementation in February of 2026.

HQS inspections will be documented in each tenant’s file in accordance with applicable standards, along with the corresponding inspection log maintained by the PHA. Any required reinspection will also be completed and documented accordingly in the tenant’s file.

Corrective action Plan: Due to the termination of activities as mentioned in Note 8 of the financial statements, the Organization is unable to develop and implement a corrective action plan.

Corrective action Plan: Due to the termination of activities as mentioned in Note 8 of the financial statements, the Organization is unable to develop and implement a corrective action plan.

Department of Education, passed through the State of Montana Office of Public Instruction, Federal Financial Assistance Listing 84.010, federal award numbers S010A240026 and S010240026, grant period 7/1/2024 – 9/30/2026 Title I Grants to Local Education Agencies Special Tests and Provisions Finding Summary: During the auditor’s federal program testing of Title I, it was noted that several students were removed from the adjusted cohort for unallowable reasons. Corrective Action Plan: The District staff will follow the guidance in ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)), to ensure graduation rate data is reported correctly going forward. Responsible Individual: Laurie Kvamme, Chief Financial Officer Anticipated Completion Date: June 30, 2026

Finding Correction Action Plan Details 2025-001 a. Name of Contact Person Responsible for Corrective Action: Michelle Cage – Chief Financial Officer b. Corrective Action Planned: Management will continue to implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets, and compliance with federal grant requirements. c. Anticipated Completion Date: Immediately.

a. material weakness - Condition: During our testing of expenditures charged to the grant, we noted that a paymnet for contracted services was charged to payroll costs. The error was subsequently corrected by the district. Expendituresshould be charged to appropriate account codes. b. Plan of action - The responsible officials recognize the importance of ensuring expenditures are charged to the appropriate account codes. There was a misunderstanding on the form that was filled out for the oregon department of education. This error was corrected with a journal entry. Additionally, the account codes used for federal awards will be reviewed for accuracy on an annual basis. C. Timing: Correcting journal entry was completed on 6/30/2025

Recommendation: CLA recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases, along with adding controls to ensure that the item purchased was received by the District. CLA also also recommends the District printout the eligibility reports from Wisegrants and sign and date them to indicate review and approval after meeting with CESA 10 each year. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The District will note the date of the budget meeting with CESA 10. When items are purchased for Title I, approval will be made by either the Elementary Principal or Superintendent before purchases are made. Name(s) of the contact person(s) responsible for corrective action: Brooke Rosemeyer, Adrian Foster, Brandon Baldry Planned completion date for corrective action plan: September 1, 2026.

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Children's Health Insurance Program Federal Assistance Listing Number: 93.767 Material Weakness and Nonmaterial Noncompliance - Eligibility Finding 2025-002 - Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination, and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) Self-attestation wages should be compared to information in NC FAST. b) All countable resources should be confirmed and recalculated and ensure they are computed accurately in NC FAST. c) The caseworker should prepare and submit a DMA-5097 form in the case of incompatible income verification and self-attestation income as described in the Eligibility Review Document. d) Citizenship should be documented within NCFAST. e) Household information should be entered correctly into NCFAST. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 124 program participants selected for testing: a) There were six instances where the participants self-attest wages did not agree to the wages entered into NC FAST. b) There was one instance where the countable resources were inaccurate within NC FAST. c) There were five instances where the income was incompatible between the income verification and self-attestation income but no DMA-5097 was sent. d) There was one instance where the participant's citizenship was not documented in NCFAST. e) There was one instance where the participant's household size was entered incorrectly into NCFAST. Lastly, there were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Context: There were 8 out of 124 unique participants tested with the errors noted above. Questioned Costs: We noted no federal questioned costs for the County as the State of North Carolina makes all benefit payments to participants directly. Due to split eligibility determinations between the Counties and the State of North Carolina for Medicaid, we found $25,105 in benefit payments made by the State of North Carolina to ineligible participants based on an improper eligibility determinations at the County related to three individuals in item "a" above. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: The County has identified specific opportunities to strengthen accuracy and consistency in eligibility case documentation. While overall performance has improved, with total errors reduced from 14 the prior audit period to 8 in the current period, continued focus is necessary to further reduce errors and sustain compliance across case files. The Economic Services Division Strategies are as follows: • Social Services Supervisors will conduct targeted reviews of identified error trends, emphasizing policy application, documentation completeness, and process standardization to ensure consistent eligibility determinations across the program. • The Economic Services Division's Staff Development Unit will continue to quality sample cases to promote accuracy and accountability. • Social Service Supervisors, in coordination with Medicaid Social Services Managers will coach staff based on audit findings, monitor trends and ensure required corrections are completed within 5 business days of notification. • Failure to complete corrections within the approved timeframe will result in corrective action to both the Social Services Supervisor and the assigned Eligibility Specialist in accordance with departmental performance management protocols. • Supervisory staff will ensure all updates to the Quality Sampling Tracking Log are finalized no later than the 20th calendar day of the subsequent month to support timely monitoring, trend analysis, and corrective action. These actions are designed to strengthen internal controls, support staff performance and maintain compliance with applicable state and federal requirements. Responsible lndividual(s): Kim Konior, Lynn Martin (Medicaid Program Managers), Staphon Snelling (Training and Development Manager), Danisa Concepion, Donnie Munson (Quality and Training Supervisors), and Social Services Medicaid Supervisors. Anticipated Completion Date: Ongoing Training: The Economic Services Division's Staff Development Unit will review the Single Audit findings and develop targeted training for staff responsible for determining Medicaid eligibility, as well as their supervisors and managers. This training will specifically address the errors identified in the audit and will be delivered by the end of March 2026. In addition, Staff Development will provide quarterly training to Medicaid eligibility staff, supervisors, and managers based on error trends identified through quality sampling conducted by the unit. To ensure effectiveness, a structured training approach will be used: • A pre-test will assess staffs current understanding of relevant policies. • The County will deliver targeted training materials tailored to address identified gaps. • A post-test will be developed, with a minimum passing score of 90%. This approach will allow the County to: • Measure knowledge gained through the training • Track training completion, identify staff who have or have not completed the training • Ensure consistent understanding and application of policy across the team Staff who do not achieve the required score will receive additional refresher training to reinforce key concepts and ensure compliance. Responsible lndividual(s): Staphon Snelling (Training and Development Manager), Danisa Concepion, and Donnie Munson (Quality and Training Supervisors), and Sr. Quality and Training Specialists (Medicaid). Anticipated Completion Date: March 31, 2026

Condition: The Village did not have adequate controls in place to exercise its oversight responsibility of adherence to wage rate requirements that were reviewed by a contractor for the program. The Village also did not have controls in place to exercise oversight over the same contractor's review of general and subcontractors for suspension and debarment. Planned Corrective Action: The Village has implemented updated procedures as recommended by the auditors. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2025

Condition: Controls were not in place to ensure that the schedule of expenditures of federal awards (SEFA) was complete and accurate. Planned Corrective Action: The Village has hired an outside contractor to assist with review of audit documents. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2025

Condition: The Village did not have written policies for cash management or procurement that adhered to the requirements of the Code of Federal Regulations. Planned Corrective Action: The Village is currently reviewing existing policies to determine the best course of action and updating them for compliance. Some updates may require voter approval as certain provisions are in the Village Charter. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2026